State of Iowa v. Benjamin Joseph Lyon, 2015 Iowa Sup. LEXIS 47

Around 2:00 a.m., Polk County Deputy Jason Tart followed and stopped Benjamin Lyon’s vehicle after observing what Tart believed was an unlit rear license plate in violation of Iowa Code § 321.388; Tart testified he ensured his headlights did not reflect on the plate when observing it.
At the scene Lyon was given field sobriety tests and arrested for OWI; at the station he received Miranda warnings and the implied-consent advisory and was allowed to make three phone calls before being asked for a breath sample, which he refused.
Lyon moved to suppress, arguing (1) the traffic stop lacked reasonable suspicion because the deputy was too far to determine the plate’s legibility at the statutory fifty-foot measure and his own headlights interfered, and (2) the officer violated Iowa Code § 804.20 by failing to explain the purpose of the statutorily permitted phone call (and by offering calls before requesting a breath sample).
The district court denied the suppression motion, the jury convicted Lyon of OWI (second offense), and the court of appeals affirmed; the Iowa Supreme Court granted further review.
The Supreme Court vacated the court of appeals decision and affirmed the district court, holding the stop and the § 804.20 phone-call handling lawful.

Issue	Plaintiff's Argument (Lyon)	Defendant's Argument (State/Deputy)	Held
Validity of stop under Iowa Code § 321.388 / Reasonable suspicion	Tart was too far to assess whether the plate was legible at 50 feet; his headlights later interfered, so no reasonable suspicion	Tart observed no illumination and trailed at a distance to avoid headlight reflection; absence of any plate illumination supports suspicion	Stop valid: officer reasonably suspected either no plate illumination or insufficient illumination; Reisetter limited/overruled as to total absence of illumination
Duty to inform arrestee of purpose of § 804.20 phone call	Officer should have told Lyon the call’s purpose (to obtain advice about chemical testing); offering calls before asking for a breath sample undermined that right	Officer had no affirmative duty to describe purpose once calls were permitted; timing was proper because implied-consent advisory had been given	No violation: officer did not mislead and had no duty to shape the call’s content or specifically state testing-advice purpose

Mendenhall v. United States, 446 U.S. 544 (U.S. 1980) (defining when a person is "seized" for Fourth Amendment purposes)
Atwater v. City of Lago Vista, 532 U.S. 318 (U.S. 2001) (scope of arrest authority for minor offenses)
Kinkead v. State, 570 N.W.2d 97 (Iowa 1997) (de novo review of constitutional claims involving searches/stops)
Reisetter v. State, 747 N.W.2d 792 (Iowa Ct. App. 2008) (officer too far to resolve 50-foot legibility prong; limited by this decision)
Tyler v. State, 830 N.W.2d 288 (Iowa 2013) (federal Fourth Amendment standards applied to state claims, with reservation of stricter state application)
Garrity v. State, 765 N.W.2d 592 (Iowa 2009) (officer must advise whom an arrestee may call under § 804.20 when request falls outside statute’s scope)
Tubbs v. State, 690 N.W.2d 911 (Iowa 2005) (one purpose of § 804.20 is to allow counsel consultation before deciding on chemical testing)
Didonato v. Iowa Dep’t of Transp., 456 N.W.2d 367 (Iowa 1990) (officer must advise purpose of a phone call when arrestee requests to call someone not clearly within statutory scope)